CMS Proposed Changes to the HHQRP
July 27, 2015 09:26 AM
In the proposed rule for the calendar year (CY) 2016 Home Health Prospective Payment System Rate Update, the Centers for Medicare & Medicaid Services (CMS) proposes additional home health quality reporting requirements as part of the home health quality reporting program (HHQRP).
The HHQRP requires that home health agencies submit selected quality data in order to receive the full annual payment update (APU) for the payment year associated with the respective reporting year. Agencies that do not submit the quality data, as required by the HHQRP, are subject to a 2% market basket percentage reduction in payments.
The current HHQRP requires agencies to submit 70% of their Outcome and Assessment Information Set (OASIS) quality assessments and quarterly Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) data in order to receive the full APU.
In the proposed rule, CMS proposes to increase the OASIS assessment submission threshold to 80% for the reporting year that begins July 1, 2016, through June 30, 2017, for payment year 2018, and 90 % for the reporting year July 1, 2017, through June 30, 2018, for payment year 2019 and forward.
In addition to the current quality data HHAs are require to report, CMS is proposing one new quality measure that will be required for the implementation of the Improving Medicare Post- Acute Care Transformation (IMPACT) Act.
The IMPACT Act was passed in September 2014 and requires the CMS to develop quality measures, resource use measures, and assessment data to be used across post-acute care (PAC) providers. PAC providers identified in the IMPACT Act include skilled nursing facilities, long term care hospitals, inpatient rehabilitation facilities and home health agencies. The Act also requires that CMS develop quality measures and standardized data elements under eight specific domains and within specified application dates for each PAC provider.
The eight domains are as follows:
Functional and cognitive status and changes in functional and cognitive status
Skin integrity and changes
Incident of falls
Transition of care
Resource use measures, including total estimated Medicare spending per beneficiary;
Discharge to community; and
Measures to reflect all-condition risk- adjusted potentially preventable hospital readmission rates
CMS must select measures under the domains of skin integrity and medication reconciliation by 2017 for HHAs. For Calendar year 2016, CMS is proposing to require HHAs begin reporting a quality measure that addresses the domain of skin integrity and changes in skin integrity. The National Quality Forum (NQF)-endorsed measure: Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened (Short Stay) (NQF #0678) has been selected. The measure would be collected using the OASIS items M1308 (Current Number of Unhealed Pressure Ulcers at Each Stage or Unstageable) and M1309 (Worsening in Pressure Ulcer Status Since SOC/ROC). Since this measure is already collected by agencies from the OASIS assessment there should not be any addition administrative burden associated with collecting and reporting the proposed measure. The IMPACT Act requires that CMS implement its provisions with as little administrative burden to providers as possible.
CMS is considering a future update to the numerator of the new quality measure. This update would hold providers accountable for the development of unstageable pressure ulcers and suspected deep tissue injuries (sDTIs). At this time, CMS is not proposing the implementation of this change (that is, including sDTIs and unstageable pressure ulcers in the numerator) in the HH QRP, but is soliciting public feedback on this potential area of measure development. CMS is also seeking public feedback on whether height and weight as a measure of body mass index should be used as a covariate for risk-adjusting the measure in the home health setting, as is done in other post-acute care settings.
CMS proposes to include the new skin integrity measure in the HHQRP which would affect CY 2018 and subsequent year payment determinations. CMS does not specify how payments will be impacted but will most likely follow the current payment adjustment of 2% market basket reduction for non-compliance. The IMPACT Act also contains a public reporting requirement of the cross setting measures that CMS must implement.
In addition to the one new measure, CMS proposes four future cross-setting measure constructs within the domains of: (1) All condition risk-adjusted potentially preventable hospital readmission rates; (2) resource use, including total estimated Medicare spending per beneficiary; (3) discharge to community; and (4) medication reconciliation. CMS is seeking public feedback to inform them on future measure developments as it relates to meeting the IMPACT Act requirements (see Table 22 in the proposed rule).
CMS must complete cross setting measure development and selection, and cross setting assessment data elements by 2019. Therefore, there has already been much activity within CMS to meet these requirements. Several Technical Expert Panels are been convened and we should begin to see increased notices of proposed rulemaking (NPRM) as the measures and assessment data are developed.
The National Association for Home Care & Hospice encourages providers to review the proposed rule and CMS’ plans for implementing the IMPACT Act. Input from the home health industry will be vital in ensuring that the IMPACT Act is implemented with due consideration towards home health agencies and with the least amount of burden.